| Comment Number: | 522418-02291 |
| Received: | 6/15/2006 11:01:30 AM |
| Organization: | Sunrider International |
| Commenter: | Karen Spencer Dees |
| State: | MA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| No Attachments |
Comments:
Karen Spencer Dees June 15, 2006 Dear Sir or Madam: I am writing in response to the proposed Business Opportunity Rule R511993. Reading the bill it alarms me in several ways. First, I believe that it could prevent me from continuing as an Independent Sunrider Distributor. I understand that part of the FTC’s responsibilities is to protect the public from deceptive acts, but some of the sections in the proposed rule would make it impossible for me to do business. I find it very confusing and even slowing down the free enterprise aspect of my business in reference to the seven-day waiting period to enroll new people. To enter our business the cost is $140.00, and even this is an option, not mandatory. I can show thousands of purchases across America that far exceed $140.00 that do not require this rule, why our industry? This waiting period sends a negative impression to those entering my business. In addition, Sunrider already offers a 60-day return policy which ‘more than guarantees’ the new prospect the opportunity to withdraw if he/she wishes. In my office we have already created enough paperwork and filing that just the nightmare alone of the additional administrative burden both on my side and reports that I would then have to send to Sunrider would be overwhelming. It is also in the rule that Sunrider must release any information in reference to previous lawsuits. As you know, today we are in a nation of lawsuits, with more than 73% being frivolous. Why put a corporation, like Sunrider, under the position of doubt when in the process of adding new distributors. This rule is not correct, plus anyone with Internet can check on any corporation if they desire. Page Two I also find the proposed rule requiring the disclosure of those purchasing our product as a threat in doing business. I have no challenge in showing receipts, however, today we are seeing a rash of identity theft and stealing of personal information, with the largest area of theft coming from our Government Agency’s (Veterans etc.). Having a client understand that his/her name, address and other information is being sent to the government is like asking people if they would like to go swimming with a 50 pound weight around their waist. I refuse to give any of my personal information to ANYONE. I have been a Sunrider Distributor for more than 15 years. I have created a very solid business based upon business principles of ethics and character. My personal income and lifestyle is a direct result of the Sunrider business and this industry. In closing, I thank the FTC for it’s work in the protection of consumers, but it is my personal belief this rule far extends the boundary of protection and moves to the hindering the Free Enterprise System. I am confident, with those who are active in this industry, with a proven record, could be summoned to the FTC to write a document that would allow for the protection of the consumer while promoting the value of Free Enterprise. Thank you for your time, Sincerely, Karen Spencer Dees, PhD